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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`_____________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`_____________________
`
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`NEVRO CORP.,
`Petitioner
`
`v.
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`BOSTON SCIENTIFIC NEUROMODULATION CORP.,
`Patent Owner.
`
`_____________________
`
`Case IPR2018-00148
`U.S. Patent No. 8,646,172
`_____________________
`
`
`PETITIONER’S REQUEST FOR
`REHEARING OF INSTITUTION DECISION
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`
`
`
`
`
`
`
`Mail Stop “Patent Board”
`Patent Trial and Appeal Board
`U.S. Patent & Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`
`
`IPR2018-00148
`U.S. Patent No. 8,646,172
`
`TABLE OF CONTENTS
`
`I.
`
`
`The ’172 patent Claims are Broad – Broader Than the ’747 and ’085
`Patents Already Reviewed by this Panel. ........................................................ 1
`
`II.
`
`Standard of Review .......................................................................................... 3
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`III. Argument ......................................................................................................... 3
`
`A.
`
`The Panel’s dispositive fact findings for the Stolz and Black
`references lack substantial evidentiary support. ................................... 3
`
`1. Stolz ...................................................................................... 4
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`2. Black ..................................................................................... 7
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`3. The Panel failed to evaluate Nevro’s expert testimony. ..... 11
`
`B.
`
`The Board used the wrong legal standard in evaluating
`obviousness. ........................................................................................ 12
`
`IV. Expanded panel review is appropriate here. .................................................. 13
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`V.
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`Conclusion ..................................................................................................... 15
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`IPR2018-00148
`U.S. Patent No. 8,646,172
`Petitioner Nevro Corp. requests rehearing because at least two of the
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`Board’s material fact findings lack substantial evidentiary support, and because its
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`legal analysis is flawed. Both are an abuse of the Panel’s discretion.
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`Nevro also respectfully requests that an expanded panel reconsider the
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`Panel’s decision denying institution of inter partes review of U.S. Patent No.
`
`8,646,172 to resolve inconsistencies in how individual Board panels treat expert
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`testimony at the pre-trial phase where the Patent Owner chooses not to introduce
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`competing testimony, as was the case here. See IPR2018-00148, Paper No. 7
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`(PTAB May 17, 2018). Standard Operating Procedure 1, Rev. 14 (May 8, 2015),
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`Section III.C. Expanded panel review will improve uniformity and predictability in
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`how the Board will evaluate evidence and arguments in the pre-trial phase of an
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`IPR proceeding where a patent owner does not submit competing declaratory
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`evidence.
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`I.
`
`The ’172 patent Claims are Broad – Broader Than the ’747 and ’085
`Patents Already Reviewed by this Panel.
`
`The ’172 patent is related to U.S. Patent Nos. 7,891,085 and 8,650,747. Both
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`the ’085 and ’747 patents are involved in IPR proceedings before this Panel where
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`it denied institution on similar facts and art.1 Both patents are also narrower than
`
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`1 IPR2018-00143, Paper 7 (’085 patent) and IPR2018-00147, Paper 7 (’747
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`patent). Petitioner Nevro did not request rehearing for the ’085 patent.
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`IPR2018-00148
`U.S. Patent No. 8,646,172
`the ’172 patent at issue for the key limitation at issue in each denial, as the chart
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`below illustrates:
`
`8,650,747
`
`Patent No. Key limitation at issue in each of the IPR denials
`inserting monofilament into at least one portion of at least one of the
`7,891,085
`conductor lumens of the lead body that is not occupied by the
`conductor wires.
`a solid, non-conductive material disposed, at least in part, radially
`underneath the conductive contacts and filling the unoccupied
`portion of at least one of the conductor lumens.
`placing non-conductive material into a portion of at least one of the
`conductor lumens of the lead body, wherein at least a portion of the
`non-conductive material is disposed radially beneath the conductive
`contacts.
`
`8,646,172
`
`The ’085 patent narrowly requires inserting monofilament into at least one of
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`the conductor lumens that is not occupied by conductor wires. The ’747 and ’172
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`patents, on the other hand, more broadly dispose “non-conductive material” in the
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`conductor lumens, instead of monofilament. And the ’747 and ’172 patents both
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`require that some portion of non-conductive material be disposed “radially beneath
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`[underneath] the conductive contacts.”
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`But the ’172 patent at issue here is broader than the ’747 patent because the
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`’172 patent claims do not require “at least in part … filling the unoccupied portion
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`of at least one of the conductor lumens.” Rather, the ’172 patent only disposes non-
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`conductive material anywhere in the conductor lumen, without restriction, so long
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`as “at least a portion” of it is “disposed radially beneath the conductive contacts.”
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`IPR2018-00148
`U.S. Patent No. 8,646,172
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`II.
`
`Standard of Review
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`As the party challenging the decision, Nevro bears the burden of showing
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`that a prior decision should be modified. See 37 C.F.R. § 42.71(d). When rehearing
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`a decision on petition, the Board will review the decision for an abuse of
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`discretion. 37 C.F.R. § 42.71(c). An abuse of discretion occurs if the decision is
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`“based on an erroneous interpretation of law, if a factual finding is not supported
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`by substantial evidence, or if the decision represents an unreasonable judgment in
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`weighing relevant factors.” Arnold P’ship v. Dudas, 362 F.3d 1338, 1340 (Fed.
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`Cir. 2004). A rehearing request must specify all matters the party believes the
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`Board misapprehended or overlooked, and the place where each matter was
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`addressed previously in a motion, an opposition, or a reply. 37 C.F.R. § 42.71(d).
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`III. Argument
`A. The Panel’s dispositive fact findings for the Stolz and Black
`references lack substantial evidentiary support.
`
`Nevro and its expert relied primarily on Stolz and Black to show at least
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`partial filling of a conductor lumen radially beneath a conductive contact. See, e.g.,
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`Pet. at 5, 11, 16–18, 22–27, 39–45; Ex. 1003, ¶¶112–157. The Panel provided no
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`evidentiary support for its contrary findings, let alone the substantial evidentiary
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`support required to avoid an abuse of discretion.
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`IPR2018-00148
`U.S. Patent No. 8,646,172
`
`Stolz
`
`1.
`The Panel correctly recognized that “Stolz discloses sufficiently a non-
`
`conductive material ‘radially beneath’ the conductive contacts, as that claim phrase
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`is reasonably broadly construed.” Inst. Dec. at 11. It made this finding based on the
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`embodiment described by Stolz’s FIG. 13.
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`In this embodiment, “[t]he coupling 112 has a conductor coupling 500 and a
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`contact coupling 502.” Pet. at 35; Ex. 1005, [0045]. “The conductor coupling 500
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`is placed over the conductor 34 and attached to the conductor 34 mechanically,”
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`and “contact coupling 502 exits the lead body and has a weld 504 to connect the
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`contact coupling 502 to the contact 36.” Ex. 1005, [0045]. “An isolation space 506
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`is created between the conductor 34 and the
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`contact 36 to prevent directly welding the
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`conductor 34 to the contact 36.” Id.,
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`¶[0046]. The Panel correctly recognized
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`that “isolation space 506 [has] a geometry
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`such that” when it is filled with epoxy, the epoxy is “disposed between the lead’s
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`center point and the conductive contacts.” Inst. Dec. at 10-11. The Panel thus
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`agreed that in Stolz, at least a portion of the non-conductive material is “disposed
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`radially beneath the conductive contacts.” Id. at 11.
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`IPR2018-00148
`U.S. Patent No. 8,646,172
`The Panel, however, incorrectly found that the epoxy in Stolz’s isolation
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`space 506 does not meet the limitation of “placing non-conductive material into a
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`portion of at least one of … conductor lumens of [a] lead body….” Inst. Dec. at 11.
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`The basis for this finding is unclear and the finding lacks substantial evidentiary
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`support.
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`Stolz’s epoxy-filled isolation space is inside a conductor lumen. In fact, the
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`Figure 13 embodiment—which includes at least in part contact coupling 502 and
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`isolation space 506— shows the latter is disposed within a conductor lumen 102
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`that extends from the proximal to the distal end of the lead. Pet. at 21-22, 23, 33,
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`39 (“Stolz discloses conductors 34 in the form of conductor wires ‘contained in the
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`conductor lumens 102 extending from the lead proximal end 38 to the distal end
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`40’,” citing Ex. 1005, [0031]). This fact is beyond dispute because according to
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`Stolz, only the top portion of contact coupling 502 exits lumen 102, so the epoxy-
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`filled isolation space 506, which is adjacent to the conductor 34, remains in the
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`conductor lumen 102. Pet. at 31; Ex. 1005, [0054] (“The contact coupling 502 is
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`further configured to exit the conductor lumen 102 and mate with the contact 36
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`while retaining the conductor 34 coplanar to the contact 36.”). The top part of the
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`contact coupling 502 cannot “exit the conductor lumen” if the rest of the contact
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`coupling, including the isolation space beneath it, were not in the conductor lumen.
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`Indeed, Stolz explicitly states that: “The coupling second region 506 [i.e., the
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`IPR2018-00148
`U.S. Patent No. 8,646,172
`isolation space] is positioned 610 in a conductor lumen 102 adjacent 620 to a
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`contact 36.” Ex. 1005, [0057] (emphasis added).
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`If the Panel is reading additional restrictions into how the non-conductive
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`material is “placed” in the conductor lumen, it does not say what those restrictions
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`are, nor does it provide any basis for such restrictions. The Panel alleges that
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`contact coupling 502 may provide a barrier to the remainder of the distal portion of
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`the conductor lumen. Inst. Dec. at 11. But even if that were true, it is immaterial
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`since independent claim 1 places no restriction whatsoever on how the non-
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`conductive material is “place[d]” “into a portion … of the conductor lumens.”
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`To draw an analogy, imagine a claim that has the step of “placing peanuts
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`into a pail.” Without more, that claim element is met whether loose peanuts are
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`placed into the pail, or whether a bag of peanuts are placed into the pail. In both
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`instances, the peanuts are placed in the pail. So the Panel’s observation that
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`coupling 112 “surrounds isolation space 506,” Inst. Dec. at 11, does not mean that
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`the non-conductive material that fills isolation space 506 is not also placed into at
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`least a portion of the conductor lumen—it clearly is. The Board’s finding to the
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`contrary lacks substantial evidence. This error alone warrants reversal.
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`Stolz, alone, in the embodiment described in Figure 13, thus meets this
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`claimed feature, as Petitioner Nevro unambiguously argued in its Petition. See e.g.,
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`Pet. at 24, 37-39. But lest there be any doubt that this feature is obvious, Nevro did
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`IPR2018-00148
`U.S. Patent No. 8,646,172
`not stop with Stolz. Pet. at 10-11. It provided further evidence that this feature
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`would have been obvious in view of Black. Pet. 22–27, 29–45.
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`Black
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`2.
`The Board correctly acknowledged that “Black suggests filling spaces within
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`elongate structures with non-conductive material.” Inst. Dec. at 17. Those
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`“elongate structures,” of course, refer to Black’s conductor lumen. But the Board
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`mistakenly rejected Petitioner’s contention that Black also, at least in part, fills
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`spaces radially beneath the conductive contacts. Id. There is no substantial
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`evidence supporting the Board’s fact finding on the latter finding.
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`Black discloses reflowing its spacers into the conductor lumen to stabilize
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`and strengthen the structural elements therein within “a fused matrix of material”
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`that is “free of gaps and voids.” See Pet. at 47; Ex. 1008, 6:19-34, 7:11-24, 7:29-
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`34, FIG. 5; see also Ex. 1003, ¶¶161-162. Figure 3 illustrates Black’s conductor
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`lumen as reproduced on page 43 of the Petition.
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`
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`The circular conductors 20 are disposed around a center stylet 100, and
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`stylet tubing 24. Pet. at 42-43; Ex. 1008, 5:28-45, 6:5-10, 7:12-23. The conductor
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`lumen is thus the cylindrical (toriodal- or donut-shaped) space between the stylet
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`IPR2018-00148
`U.S. Patent No. 8,646,172
`tubing 24 and the outer tubing 22, 23. Black’s conductors 20 are disposed in that
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`conductor lumen. Pet. at 42-43. As one moves towards the distal end of Black’s
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`lead, the number of circular conductors in the toriodal lumen will progressively
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`drop. Pet. at 42-43; Ex. 1008, 5:28-45. Thus, serially along the lead, there exists a
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`space where the respective conductor ends (at its respective conductive contact),
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`and the unoccupied portion of the lumen continues (i.e., the segment without any
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`conductor wires), all the way to the distal end. Although Black does not show a
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`cross section at the distal end of the lead, it would look like this between the two
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`most distal electrodes:
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`
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`When the oversized insulative spacers (which are not shown in Figure 3 but
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`are cylindrical elements disposed around outer tubing 22, 23) are placed into a
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`state of flow, they flow together into the unoccupied portions of Black’s toriodal
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`lumen. Non-conductive material is thus placed into Black’s lumen—i.e.,
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`“supported by a fused matrix of material.” Pet. at 42-43; Ex. 1008, 5:28-45, 6:5-10,
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`7:12-23; see also Ex. 1003, ¶¶ 151-156. The result, as Black explains: “an
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`isodiametric lead is obtained, which is further free of any gaps or spaces between
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`IPR2018-00148
`U.S. Patent No. 8,646,172
`the insulative material and conductive material that may otherwise exist in
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`conventional devices.” Ex 1008, 7:29-33; see Pet. at 26, 42–44.
`
`The Panel’s fact finding is confusingly contradictory to its conclusion. The
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`Panel states: “[b]ut all that Black discloses is that regions between terminals
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`16/electrodes 18 and stylet guide 24 are filled.” Inst. Dec. at 18, citing Ex. 1006,
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`7:13-18 (Panel’s emphasis). This is absolutely true, but it supports Nevro’s
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`position that this material is placed into a conductor lumen and is disposed radially
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`beneath the contacts, not the Panel’s.
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`Black accomplishes this filling process in a two-step process: (1) by placing
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`oversized spacers made of non-conductive material on the lead, and (2) heating the
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`lead so the spacer material is placed radially beneath the conductive contacts. The
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`following figures from Black show how the spacers are disposed on Black’s lead:
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`
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`The “terminals 16/electrodes 18” are the circular conductive contacts that
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`are disposed around the body 22/outer tubing 23, with the terminals 16 at the
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`proximal end and the electrodes 18 at the distal end. The oversized spacers 28 are
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`IPR2018-00148
`U.S. Patent No. 8,646,172
`likewise disposed around the outer tubing 23, in between conductive contacts
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`16/18. The stylet guide 24 defines the external perimeter of Black’s internal most
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`stylet lumen, and the interior perimeter of Black’s toriodal conductor lumen.
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`As the Panel and the Petition correctly recognized, Black then discloses the
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`second heating step that causes the spacer material to flow. Black states that the
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`“beneficial effect of unitizing the element assembly to form lead 10” is that the
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`electrode and terminal spacers are “placed in a state of flow, which, at least in part,
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`results in a filling of the regions between terminals 16/electrodes 18 and stylet
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`guide 24.” Ex. 1008, 7:12-16. Black continues, stating that “[c]onsequently,
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`terminals 16 and electrodes 18 are partially surrounded (i.e., along an interior
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`surface) and supported by a fused matrix of material.” Pet. at 43–44, 47; Ex. 1008,
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`7:16-18 (emphasis added).
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`The Panel’s finding to the contrary—namely, “[t]here is no disclosure that,
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`upon over-molding, the spacer material fills a conductive lumen space beneath the
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`conductive contacts,” Inst. Dec. at 18—has no technical merit and cannot be
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`reconciled with Black. If the space between Black’s terminals 16 / electrodes 18
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`[i.e., the conductive contacts] and the stylet guide 24 [which defined the innermost
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`stylet lumen] is filled as the spacer material flows, and if that causes the terminals
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`16 / electrodes 18 [i.e., the conductive contacts] to become partially surrounded
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`“along an interior surface” by the “fused matrix of material,” as Black
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`IPR2018-00148
`U.S. Patent No. 8,646,172
`unambiguously discloses, it is simply inconceivable that the non-conductive spacer
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`material and outer tubing 23 (which are formed of “mechanically equivalent”
`
`material, Ex. 1008, 7:20) are not disposed in Black’s conductor lumen, with some
`
`portion of that material radially beneath its conductive contacts, as the claims
`
`require. This is precisely what Nevro argued in its Petition. See Pet. 43-44. Even
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`the Patent Owner did not dispute this view of Black.
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`The Board also erred in reading limitations into the claims by suggesting
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`Black had to show that the non-conductive material completely filled the space
`
`under the conductive contacts. See Inst. Dec. at 18 (“But there is insufficient
`
`evidence that there is a ‘complete filling of its conductor lumen space beneath its
`
`conductive contacts,’ as argued (Pet. 44).”). But the ’172 patent claims make no
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`such demand.
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`In sum, the Panel’s interpretation of Black is technically unsupportable and
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`finds no substantial evidentiary support. The Panel thus abused its discretion in
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`finding that Black does not disclose a lead where at least “a portion of the non-
`
`conductive material is disposed radially beneath the conductive contacts.”
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`The Panel failed to evaluate Nevro’s expert testimony.
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`3.
`Throughout its petition, Nevro cites the expert testimony of Michael Plishka.
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`Pet. et. seq., Ex. 1003. Mr. Plishka is highly qualified in the relevant field of
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`implantable medical devices and related technologies. Ex. 1004 (Plishka CV). The
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`IPR2018-00148
`U.S. Patent No. 8,646,172
`Panel made no finding that Mr. Plishka is not qualified as an expert, or that his
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`testimony is not credible. Indeed, the Panel did not address his testimony at all.
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`Even the Patent Owner did not challenge Mr. Plishka’s credibility.
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`The Panel, without substantial evidentiary support or explanation, erred by
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`effectively substituting its judgment for the sworn testimony of Nevro’s expert,
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`without the benefit of a trial to test that evidence, either through contrary evidence
`
`submitted by the Patent Owner or through deposition. The Panel’s decision thus
`
`represents an unreasonable judgment in weighing relevant factors, and the Panel
`
`thus abused its discretion in failing to consider Nevro’s expert testimony and in
`
`resolving factual disputes against Nevro.
`
`B.
`
`The Board used the wrong legal standard in evaluating
`obviousness.
`
`It is well-settled that one cannot show nonobviousness by attacking
`
`references individually where the rejections are based on combinations of
`
`references. In re Keller, 642 F.2d 413 (CCPA 1981); In re Merck & Co., Inc., 800
`
`F.2d 1091 (Fed. Cir. 1986). Here, the Board separately dissects each reference
`
`searching for a single express teaching for non-conductive material disposed in a
`
`conductor lumen, radially beneath a conductive contact, without considering what
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`the teachings, taken in their totality, would have suggested to a POSA. Inst. Dec. at
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`11-18. The Board then wrongly concludes that Petitioner “provides no
`
`explanation” as to “how [a POSA] … would have been led to place nonconductive
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`IPR2018-00148
`U.S. Patent No. 8,646,172
`material … ‘radially beneath’ conductive contacts, as claimed.” Id. at 18. In fact,
`
`the Petition provides several coherent, logical explanations that are fully supported
`
`by expert testimony. See, Pet. at 40-45. The Panel simply did not address them.
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`IV. Expanded panel review is appropriate here.
`The issue for expanded panel review is the Panel’s treatment, or here the
`
`lack of treatment, of Nevro’s expert testimony at the pre-trial phase of an IPR
`
`proceeding. Board panels do not consistently treat expert testimony at the pre-trial
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`phase where a patent owner has not submitted contrary testimony. Both APJs and
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`PTAB practitioners would benefit from expanded panel guidance in this regard.
`
`These issues are of an exceptional nature because the evaluation of expert
`
`testimony at the pre-trial phase arises in virtually every case that comes before the
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`Board. And expanded panel guidance on this point would lead to greater
`
`uniformity in how the Board evaluates petitions.
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`Where a patent owner submits competing expert testimony at the pre-trial
`
`phase to rebut a petitioner’s expert, the rule is clear—Board panels are required to
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`view the evidence “in the light most favorable to the petitioner solely for purposes
`
`of deciding whether to institute an inter partes review.” 37 C.F.R. § 108(c). This
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`rule makes sense because where there are genuine issues of material fact, the
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`proper place for resolving such issues is with a trial on the merits. And in practice,
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`Board panels routinely follow this rule. See e.g., Akamai Tech. Inc. v. Limelight
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`IPR2018-00148
`U.S. Patent No. 8,646,172
`Networks, Inc., IPR2016-01011, Paper 8, pp. 31-32 (PTAB 2016). But where, as
`
`here, a patent owner does not submit a pre-trial declaration, the Board has not been
`
`consistent in its treatment of a petitioner’s expert testimony.
`
`In some cases, Board panels take an approach similar to Rule 108(c). The
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`panel will evaluate a preliminary response and recognize there is a genuine issue of
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`material fact that should be resolved at trial. See e.g., Colas Solutions, Inc. v.
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`Blacklidge Emulsions, Inc., Case IPR2016-01032, Paper 9, (PTAB 2016) (“Patent
`
`Owner has neither proffered testimony from an expert nor had an opportunity to
`
`cross-examine [Petitioner’s expert] to elicit testimony from him to support its
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`arguments. On the record currently before us, we credit [Petitioner’s expert’s]
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`testimony.”); Mylan v. Sanofi, IPR2017-01526, Paper 13 at 28 (PTAB 2017) (“As
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`explained above with respect to Ground 1, we find that Patent Owner’s arguments
`
`raise disputed issues of material fact that are best resolved on a full trial record.”)
`
`This approach is most consistent with the law and purposes of an IPR trial.
`
`But in other cases, a Board panel will resolve genuine issues material fact
`
`against a petitioner and deny trial because it finds a patent owner’s arguments (or
`
`its own analysis) more persuasive than a petitioner’s evidence as to what the prior
`
`art teaches a POSA. See e.g., Nevro Corp. v. Boston Sci. Neuromodulation Corp.,
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`IPR2017-01811, Paper 11 at 10-12 (PTAB 2018); Alcatel-Lucent USA Inc. v.
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`Oyster Optics, LLC, IPR2017-02173, Paper 12, pp. 23-27 (PTAB 2018)
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`IPR2018-00148
`U.S. Patent No. 8,646,172
`(disagreeing with petitioner’s expert); Microsoft Corp. et al. v. Koninklijke Philips
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`N.V., IPR2018-00025, Paper 7, pp. 11-14 (PTAB 2018) (disagreeing with
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`petitioner’s expert). Similarly, there are cases like the present case where the Panel
`
`simply does not address a petitioner’s expert testimony, instead substituting its
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`non-expert view of the prior art for the expert’s. Taken together, these cases set up
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`perverse incentives where patent owners deliberately eschew declaratory evidence
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`at the pre-trial phase because their contrary argument could carry the day, whereas
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`contrary evidence could not. Such a scenario, however, is legally flawed because it
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`is well settled that unsworn “[a]ttorney argument is not evidence,” Icon Health and
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`Fitness, Inc. v. Strava, Inc., 849 F.3d 1034, 1043 (Fed. Cir. 2017), and it “cannot
`
`rebut . . . other admitted evidence . . . ,” Gemtron Corp. v. Saint-Gobain Corp., 572
`
`F.3d 1371, 1380 (Fed. Cir. 2009).
`
`To improve uniformity and predictability, an expanded panel of the Board
`
`should take this issue under consideration. Petitioner asks an expanded panel to
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`provide guidance to the Board (and to PTAB practitioners) so that if a petitioner’s
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`credible expert testimony raises genuine issues of material fact, those issues are not
`
`resolved at the pre-trial phase, but rather after a full trial on the merits.
`
`V. Conclusion
`The decision denying institution should be reversed, and the Board should
`
`provide guidance on the treatment of expert testimony at the pre-trial phase.
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`IPR2018-00148
`U.S. Patent No. 8,646,172
`
`Respectfully submitted,
`STERNE, KESSLER, GOLDSTEIN & FOX P.L.L.C.
`/Jon E. Wright/
`
`
`
`Jon E. Wright, Reg. No. 50,720
`Attorney for Petitioner Nevro Corp.
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`
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`
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`
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`Date: June 18, 2018
`
`1100 New York Avenue, N.W.
`Washington, D.C.20005-3934
`(202) 371-2600
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`IPR2018-00148
`U.S. Patent No. 8,646,172
`CERTIFICATE OF SERVICE
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`
`
`The undersigned certifies that a true and correct copy of the foregoing
`
`PETITIONER’S REQUEST FOR REHEARING OF
`
`INSTITUTION
`
`DECISION was served in its entirety electronically via e-mail on June 18, 2018 to
`
`the following counsel of record for Patent Owner:
`
`David A. Caine (Lead Counsel)
`Wallace Wu (Back-up Counsel)
`
`David.Caine@apks.com
`Wallace.Wu@apks.com
`
`Arnold & Porter Kaye Scholer LLP
`777 S. Figueroa Street, 44th Floor
`Los Angeles, CA 90017-5844
`Tel: (213) 243-4000
`Fax: (213) 243-4199
`
`
`
`Respectfully submitted,
`STERNE, KESSLER, GOLDSTEIN & FOX P.L.L.C.
`
`/Jon E. Wright/
`
`Jon E. Wright, Reg. No. 50,720
`Attorney for Petitioner Nevro Corp.
`
`
`
`
`
`
`
`Date: June 18, 2018
`
`1100 New York Avenue, N.W.
`Washington, D.C. 20005-3934
`(202) 371-2600
`
`
`
`
`
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